1.Who we are (data controller)
The controller of personal data described in this policy, within the meaning of Article 4(7) of Regulation (EU) 2016/679 (the GDPR), is:
Daniel Adamowicz, sole developer of Lampira, established in the Republic of Lithuania.
Email for all privacy matters: support@lampira.space
Given the scale and nature of the processing, no data protection officer has been appointed (Article 37 GDPR does not require one). All requests are handled personally by the controller.
2.Scope of this policy
This policy covers:
- the Lampira app for iPhone, iPad and Mac (bundle identifier space.lampira.app);
- the website lampira.space, including the sign-in hand-off page;
- the optional Lampira account and sync service hosted on our server in the EU.
It does not cover third-party services you choose to connect yourself (for example your own AI provider, your own iCloud, or a model running on your own computer). Those are governed by the terms and privacy policies of the respective providers.
3.Local-first: what we never receive
Lampira is built so that your study material does not depend on us. The following data is stored exclusively on your device and is never transmitted to, or accessible by, us:
- your notes, documents and their formatting and page styles;
- the content of your flashcards (questions, answers, cloze deletions);
- attachments, images, imports (Anki, RemNote, CSV, Markdown);
- mindmaps, wikilinks and your knowledge graph;
- local study statistics displayed in the app.
The app can synchronise this content between your devices through your own private iCloud (Apple's CloudKit service). That sync runs entirely between your devices and your personal Apple account: the data is stored in your private iCloud database under your Apple ID and Apple's terms, and we have no access to it — we operate no servers in that path and receive nothing from it. Apple device backups are likewise your own arrangement with Apple.
Because this data never reaches our infrastructure, we cannot read it, hand it over, restore it or delete it for you. If you use Lampira without an account, we process no personal data about you at all (apart from short-lived technical server logs if you visit our website — see Section 4).
4.What we process, why, on what legal basis, and for how long
We process only the minimum data needed to run the optional account and sync service and to keep our server secure (Article 5(1)(c) GDPR — data minimisation).
| Data category | Purpose | Legal basis | Retention |
|---|---|---|---|
| Account data — email address (or the identifier and, where you choose it, the private relay email provided by Sign in with Apple), password hash (argon2; email accounts only), account creation and sign-in timestamps | Creating and operating your account, authentication, sync across your devices, responding to account-related support | Art. 6(1)(b) — performance of a contract (providing the service you request) | Until you delete your account; then erased without undue delay, at the latest within 30 days |
| Flashcard review events — internal card/deck identifiers, review timestamps, your grade (e.g. again/good), FSRS scheduling state, device sync metadata. Never the text or content of your notes or cards | Synchronising your review history and schedule between your devices | Art. 6(1)(b) — performance of a contract | Until you delete your account (deleted together with it) |
| Server logs — IP address, timestamp, requested endpoint, response status, user-agent string | Security of the service: detecting and preventing attacks, abuse and technical faults | Art. 6(1)(f) — our legitimate interest in keeping the service secure and available. You may object (Section 9) | 30 days, then deleted automatically (retained longer only if needed as evidence of a specific security incident) |
| Support correspondence — your email address and the content of messages you send us | Handling your question, request or rights request | Art. 6(1)(b) / Art. 6(1)(f) — answering you; keeping a record of resolved requests | As long as needed to resolve the matter, then up to 24 months for continuity of support, unless law requires longer |
| App access requests — the email address you write from | Sending you the one invitation email you requested | Art. 6(1)(a) — your consent, withdrawable at any time | Until the invite is sent or you withdraw consent, whichever is earlier |
We do not use the above data for advertising, profiling or analytics, and we do not enrich it with data from other sources. Where processing rests on consent (Article 6(1)(a) GDPR), you may withdraw consent at any time with effect for the future; withdrawal does not affect the lawfulness of processing before withdrawal (Article 7(3) GDPR).
5.AI features and your data
All AI features in Lampira are optional and are designed so that Lampira's servers are never in the data path:
- Apple Intelligence (on-device). Processing happens on your device using Apple's on-device models. Your content does not leave the device through Lampira.
- Your own local model (LAN). You may point Lampira at an OpenAI-compatible server you run yourself (e.g. Ollama or LM Studio on your Mac). Data travels directly from your device to your own machine over your local network.
- Your own API key. You may connect a provider such as Gemini or any OpenAI-compatible service with your own API key. The key is stored in the device Keychain and requests travel straight from your device to that provider.
- MCP connector. A connector you attach to your own Claude, ChatGPT or Grok account. Data flows directly between your device and the provider you chose, under your own agreement with that provider.
When you connect a third-party AI provider, that provider processes the content you send it as described in its own privacy policy. You choose whether, when and what to send; we are not a party to that processing, we never proxy, store or see your prompts or the responses, and we receive no data about your use of those providers.
6.Recipients and processors
We do not sell personal data. We do not share personal data with advertisers, data brokers or analytics providers. The only recipients are:
- Hostinger (hosting provider) — operates the virtual private server on which the account and sync service runs, in a data centre in the European Union. Hostinger acts as our processor under a data processing agreement pursuant to Article 28 GDPR and processes data only on our instructions.
- Apple — if you choose Sign in with Apple, Apple (Apple Distribution International Ltd., Ireland, for EEA users) processes your sign-in under its own privacy policy. If you enable iCloud sync, Apple stores your synced content in your private iCloud database under your own Apple ID agreement — as your provider, not as our processor, and without giving us any access. Apple also distributes the app through the App Store. Apple acts here under its own responsibility, not as our processor.
- Public authorities — only where disclosure is required by a legal obligation binding on us (Article 6(1)(c) GDPR), for example a valid order of a court or competent authority.
7.International data transfers
Our server is located in the European Union, and we do not transfer personal data outside the European Economic Area.
If you use Sign in with Apple, Apple may process limited sign-in data outside the EEA (including in the United States). For such transfers Apple relies on its certification under the EU–U.S. Data Privacy Framework and, where applicable, on European Commission Standard Contractual Clauses, as described in Apple's privacy documentation.
8.Security measures
In line with Article 32 GDPR, we apply technical and organisational measures appropriate to the (deliberately small) risk profile of the service:
- Architecture as the first safeguard: the most sensitive data — your study content — never leaves your device, so it cannot be breached on our side.
- Encryption in transit: all connections between the app, the website and the server use TLS.
- Password protection: account passwords are hashed with argon2; we never store or see plain-text passwords.
- On-device credential storage: tokens and credentials on your device are stored in the Apple Keychain.
- Data minimisation and separation: review events carry no card content and are keyed to internal identifiers.
- Server hardening: firewalled EU-based VPS, timely security updates, access restricted to the controller, logs auto-deleted after 30 days.
In the unlikely event of a personal data breach we will act in accordance with Articles 33 and 34 GDPR, including notifying the supervisory authority and, where required, affected users.
9.Your rights under the GDPR (Articles 15–22)
With respect to the personal data we process, you have the right to:
- Access (Art. 15) — obtain confirmation whether we process your data and a copy of it;
- Rectification (Art. 16) — have inaccurate data corrected and incomplete data completed;
- Erasure (Art. 17) — have your data deleted ("right to be forgotten"), including by deleting your account;
- Restriction of processing (Art. 18) — in the situations set out in the GDPR (e.g. while a dispute about accuracy or an objection is examined);
- Data portability (Art. 20) — receive the data you provided under contract or consent in a structured, commonly used, machine-readable format (we can provide your account data and review events as JSON);
- Object (Art. 21) — to processing based on our legitimate interests (Section 4, server logs), on grounds relating to your particular situation; we will stop unless we demonstrate compelling legitimate grounds;
- Withdraw consent (Art. 7(3)) — at any time, where processing is based on consent;
- Not be subject to solely automated decisions with legal or similarly significant effects (Art. 22) — we make no such decisions (see Section 14).
10.How to exercise your rights
- In the app: Settings → Account → Delete Account deletes your account and all associated review events from our server. This is immediate and does not require contacting us. Your local notes and cards remain untouched on your device.
- By email: write to support@lampira.space from the address linked to your account (or describe your request so we can verify it concerns your data). Where we cannot identify you, we may ask for additional information strictly for verification (Article 12(6) GDPR).
We respond within one month of receiving your request. For complex or numerous requests this may be extended by up to two further months; we will tell you within the first month if so, with reasons (Article 12(3) GDPR). Exercising your rights is free of charge unless requests are manifestly unfounded or excessive.
11.Right to lodge a complaint
If you believe our processing infringes the GDPR, you have the right to lodge a complaint with a supervisory authority (Article 77 GDPR), in particular in the EU member state of your habitual residence, place of work or the place of the alleged infringement. Our lead supervisory authority is:
Valstybinė duomenų apsaugos inspekcija (State Data Protection Inspectorate of the Republic of Lithuania)
L. Sapiegos g. 17, LT-10312 Vilnius, Lithuania
vdai.lrv.lt · ada@ada.lt
We would, of course, appreciate the chance to resolve any concern first — write to support@lampira.space.
12.Children
The Lampira account and sync service is not directed at children under 16, and we do not knowingly collect personal data from them. Under the Lithuanian Law on the Legal Protection of Personal Data, a child may consent to information society services from the age of 14; consistent with the cautious approach recommended in the guidance of the State Data Protection Inspectorate (VDAI), Lampira nevertheless applies a uniform minimum age of 16 for creating an account.
The app itself, used without an account, stores data only on the device and involves no collection of personal data by us. If you believe a child under 16 has created an account, contact support@lampira.space and we will delete it.
13.Cookies
The lampira.space website uses no analytics, no trackers and no third-party cookies. The only cookie we set is a single first-party session cookie on the sign-in hand-off page (the page that passes your sign-in from the browser to the app):
| Cookie | Purpose | Type | Duration |
|---|---|---|---|
| lampira_handoff | Maintains your sign-in state for the few moments needed to hand the session over to the app | First-party, strictly necessary | Session — deleted when the browser session ends |
Because this cookie is strictly necessary to provide a service you explicitly request, it is exempt from the consent requirement of Article 5(3) of Directive 2002/58/EC (ePrivacy) as implemented in the Lithuanian Law on Electronic Communications. That is why lampira.space has no cookie banner — there is simply nothing to consent to.
14.Automated decision-making and profiling
We carry out no automated decision-making producing legal or similarly significant effects (Article 22 GDPR) and no profiling. The FSRS spaced-repetition algorithm schedules your reviews, but it runs on your device, on your data, solely to help you study — it is a feature you control, not a decision about you.
15.Changes to this policy
We may update this policy when the service or the law changes. The "Last updated" date at the top always reflects the current version. For material changes — in particular any new category of data, new purpose or new recipient — we will give advance notice in the app or on lampira.space at least 14 days before the change takes effect and, where the change relies on consent, ask for it. Earlier versions are available on request.
16.Contact
Daniel Adamowicz — developer and data controller of Lampira, Republic of Lithuania.
Privacy, data protection and any other questions: support@lampira.space
This policy is provided in English and Russian. In case of any discrepancy, the English version prevails. Nothing in this policy limits the rights you have under the GDPR or Lithuanian law.